Tariff restructuring did not defeat an existing exemption where the amendment was only nominal and not a substantive withdrawal.

Tariff restructuring from six digits to eight digits, including insertion of the item "other" in the relevant heading, did not by itself extinguish an existing exemption under Notification No. 67/95-CE. The amendment was treated as a change in nomenclature arising from tariff reclassification, not a substantive withdrawal of the exemption scheme. Because the benefit had already been enjoyed for years and there was no that the amendment was intended to take away accrued exemption rights, the assessee continued to qualify for the exemption and the Revenue's challenge failed.

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Issues: Whether the assessee continued to be entitled to the benefit of Notification No. 67/95-CE after the tariff entry was altered by restructuring from six digits to eight digits and the addition of the item "other" in the relevant heading.

Analysis: The addition made in the tariff heading was treated as a consequence of tariff restructuring and not as a substantive change in the scheme. The benefit of the exemption had been enjoyed by the assessee for many years, and there was no indication that the amendment was intended to withdraw an existing exemption or take away accrued benefits. The alteration in nomenclature did not alter the substance of the exemption already available.

Conclusion: The assessee remained entitled to the exemption, and the Revenue's challenge failed.

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